guide to primary production food and feed hygiene ... · herbs as well as their transport within...

Guide to Primary

Production Food and

Feed Hygiene

Inspections in Scotland

Version 3, March 2011

If you require this information in an alternative format – such as audio, large print, Braille – please contact us.

CONTACT TELEPHONE 01224 285175

2 Enforcement Guide to Primary Production March 2011

Summary

Intended audience: This guidance is applicable to local authority enforcement

officers.

Regional coverage: This guidance is applicable to Scotland.

Purpose: This guidance is intended to provide advice on the primary

production food and feed hygiene enforcement regime in

Scotland, which is described in Annex 10 of the Food Law

Code of Practice (Scotland). The relevant legislation is

EC Regulation No. 852/2004 and EC Regulation No.

183/2005.

Legal status: This guidance is dual purpose and is intended to

accompany regulations and address best practice.

Essential actions to

comply with

regulation(s):

It is the responsibility of the Food and/or Feed Business

Operator to comply with the Regulations. This guidance is

intended to help enforcement officers understand the

requirements and therefore enforce consistently and

proportionately to food and feed businesses

http://www.foodstandards.gov.scot/business-and-industry/safety-and-regulation/food-and-feed-law

http://www.foodstandards.gov.scot/business-and-industry/safety-and-regulation/food-and-feed-law

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ%3AL%3A2004%3A226%3A0003%3A0021%3AEN%3APDF





REVISION HISTORY

This guidance follows the Government Code of Practice on Guidance. If you believe this

guidance breaches the Code for any reason, please contact us using the number on the front

sheet. If you have any comments on the guidance, again please contact us on the number on

the front sheet.

Revision

No.

Revision date Purpose of revision Revised by

1

March 2011

Develop guidance based on

consultation responses

(August – November 2010)

Scottish Food

Enforcement Liaison

Committee (SFELC)

Primary Production

Enforcement Working

Group (FSA

Representation – Jacqui

Angus)

http://www.berr.gov.uk/files/file46950.pdf


TABLE OF CONTENTS

INTRODUCTION ......................................................................................................... 5

INTENDED AUDIENCE ............................................................................................... 5

PURPOSE OF GUIDANCE ......................................................................................... 6

LEGAL STATUS OF GUIDANCE ................................................................................ 6

GUIDANCE

PART 1 – OVERVIEW OF PRIMARY PRODUCTION ................................................. 7

1. BACKGROUND ......................................................................................... 7

2. WHAT IS PRIMARY PRODUCTION? ........................................................ 7

PART 2 - RISK ASSESSMENT - PRIMARY PRODUCTION FOOD AND FEED .... 11

PART 3 – ON FARM INSPECTION AND ENFORCEMENT ..................................... 12

1. NOTICE OF INSPECTIONS .................................................................... 12

2. BIO-SECURITY ....................................................................................... 12

3 ROLES OF LOCAL AUTHORITY AND SGRPID ENFORCEMENT .......... 12

OFFICERS

4. INSPECTION AND INSPECTION CHECKLISTS AND REPORTS .......... 13

5. ON FARM INCIDENTS ............................................................................ 13

6. SPPOCS DATABASE .............................................................................. 14

ANNEXES ................................................................................................................ 15

ANNEX 1: GLOSSARY ............................................................................ 15

ANNEX 2: LEGAL REQUIREMENTS AND BEST PRACTICE ................. 16

ANNEX 3: CASE STUDIES ..................................................................... 35

ANNEX 4A: BUSINESS DETAILS & INSPECTIONS SUMMARY SHEET ..46

ANNEX 4B: CHECKLIST ............................................................................ 49

ANNEX 4C: INSPECTION OUTCOME SUMMARY .................................... 54

ANNEX 5: EXAMPLES OF ANNEX II ACTIVITIES .................................. 56

ANNEX 6: WILD GAME ........................................................................... 57

ANNEX 7: OTHER SOURCES OF INFORMATION ................................. 58

ANNEX 8: CONTACTS ............................................................................ 59

INTRODUCTION

This guidance is directed to local food and feed authorities, for carrying out primary

production food and feed hygiene inspections. This guidance aims to provide advice

on the primary production enforcement regime which is described in Annex 10 of the

Food Law Code of Practice (Scotland). The scope of the guidance is as follows:


Food Feed

Livestock In Scope In Scope

Cereals In Scope In Scope

Fresh produce In Scope In Scope

Eggs Out of scope (Egg and Poultry

Unit (EPU) undertake primary

production food hygiene

inspections whilst carrying out

egg marketing inspections, and

separate guidance has been

produced for this.)

In Scope

Dairy Out of scope (existing regime in

place)

In Scope

Shellfish Out of scope (existing regime in

place)

In Scope

This guidance is to be read alongside Annex 10 of the Food Law Code of Practice

(Scotland). Food and feed authorities are required, under Regulation 7 of the Official

Feed and Food Controls (Scotland) Regulations 2009 to have regard to the Code

when discharging their duties.

INTENDED AUDIENCE

This guidance is applicable to local authority enforcement officers.

http://www.food.gov.uk/enforcement/enforcework/foodlawcop/copscotland/



http://www.legislation.gov.uk/ssi/2009/446/made

http://www.legislation.gov.uk/ssi/2009/446/made


PURPOSE OF GUIDANCE

This guidance is intended to provide advice to enforcement officers on the primary

production food and feed hygiene enforcement regime in Scotland, which is

described in Annex 10 of the Food Law Code of Practice (Scotland). The relevant

legislation is Regulation (EC) No. 852/2004 and Regulation (EC) No. 183/2005.

This document is considered a working document and shall be reviewed on an

annual basis. We would welcome feedback from Enforcement Officers on whether

this guidance provides the information which they require and comments on

presentation of information.

LEGAL STATUS OF GUIDANCE

These guidance notes have been produced to provide advice on:

the legal requirements of Regulation (EC) No. 852/2004 and Regulation

(EC) No. 183/2005 (as they relate to primary production only) and

best practice in this area.

The guidance notes have been produced for enforcement officers.








GUIDANCE

PART 1: OVERVIEW OF PRIMARY PRODUCTION

1. Background

Regulation (EC) No. 852/2004 on the hygiene of foodstuffs, and Regulation (EC) No.

183/2005 on the hygiene of feedstuffs, came into force on 1 January 2006, with a

transitional period until 1 January 2008 for feed hygiene. They apply to primary

producers of food and feed and are executed and enforced in Scotland by The Food

Hygiene (Scotland) Regulations 2006 and the Feed (Hygiene and Enforcement)

Scotland Regulations 2005, as amended, respectively.

2. What is Primary Production?

Food

Feed

Legal definitions

“the production, rearing or

growing of primary products

including harvesting, milking

and farmed animal production

prior to slaughter. It also

includes hunting and fishing and

harvesting of wild products”

“production of agricultural

products including, in particular,

growing, harvesting, milking,

rearing of animals (prior to their

slaughter), or fishing resulting

exclusively in products which do

not undergo any other operation

following their harvest,

collection, capture, apart from

simple, physical treatment”

Relevant legislation

Regulation (EC) No. 852/2004:

Articles 3, 4(1) and 4(3)) and

Annex I

Regulation (EC) No. 178/2002

Regulation (EC) No. 183/2005:

Article 4 and 5, Annex I and

Annex III (for food producing

animals)

Regulation (EC) No. 178/2002

http://www.food.gov.uk/multimedia/pdfs/hiojregulation.pdf

http://eur-lex.europa.eu/LexUriServ/site/en/oj/2005/l_035/l_03520050208en00010022.pdf

http://eur-lex.europa.eu/LexUriServ/site/en/oj/2005/l_035/l_03520050208en00010022.pdf

http://www.opsi.gov.uk/legislation/scotland/ssi2006/20060003.htm





Exemptions

legislation

from

hygiene

Primary production for private

domestic use

Domestic preparation, handling

or storage of food for private

domestic consumption

Direct supply, by the producer,

of small quantities1

of primary

products to the final consumer

or to local retail establishments

directly supplying the final

consumer2

Operations that alter the

products or introduce new

hazards e.g. peeling and slicing

vegetables, bagging salad crops

and application of preserving

gases (would be subject to

Annex II of Regulation (EC) No.

852/2004.

Food-producing animals kept

for private domestic

consumption, and for animals

not kept for food production

Feeding of food-producing

animals kept for private

domestic consumption or for the

direct supply, by the producer,

of small quantities of primary

products to the final consumer

or to local retail establishments

directly supplying the final

consumer;

Feeding of animals not kept for

food production

Direct supply of small

quantities3

of primary production

of feed at local level by the

producer to local farms for use

on those farms

Convection drying (using gas or

oil) of cereals for feed use falls

within the scope of Annex II of

Regulation (EC) 183/2005, and

will require the food business

operator to implement and

maintain procedures based on

HACCP for this process.

1

The Commission guidance (Dec 2005) suggests that the following activities be defined as „small quantities‟ (the UK has yet to issue statutory guidance)

Farmers who sell primary products (vegetables, fruits, eggs, etc.) directly to the final consumer e.g. farm gate sales or

sales at local markets, to local retail shops for direct sale to the final consumer and to local restaurants.

Individuals who collect products in the wild such as mushrooms and berries to deliver their yield directly to the final

consumer or to local retail shops for direct sale to the final consumer and to local restaurants. 2

Examples includes small producers directly supplying consumers (e.g. farm gate sales) or supplying local shops and

restaurants

3

For the purposes of feed, “small quantities” has been defined as less than 20 tonnes per annum





Primary Production includes

Production or growing of plant

products, for food use, such as

grains, fruits, vegetables and

herbs as well as their transport

within and to an establishment,

storage and handling of primary

products at the farm and their

further transport to an

establishment

Production or rearing of food

producing animals at the farm

and any activity linked therewith

as well as the transport of meat

producing animals to a market,

a slaughterhouse or the

transport of animals between

farms

The harvesting of mushrooms,

berries, snails etc. in the wild

and their transport to an

establishment

Hunting of wild game (for further

information, please see Annex

6)

Activities at the point of primary

production that merely improve

their presentation, such as

washing and trimming of

vegetables, sorting and grading

of fruit etc., air drying of cereals

Transport, storage and handling

of primary products at the place

of production

Transport operations to deliver

primary products from the place

of production to an

establishment

Mixing of feed for the exclusive

requirements of their own

holdings without using additives

(with the exception of silage

additives)

Air drying of grains

Officers involved in enforcement of primary production food and feed hygiene have a

role in identifying activities on farm that fall outside of the scope of Annex I but within

the scope of Annex II of the respective food and feed Hygiene Regulations. These

activities are not covered in the scope of this guidance and steps should be taken to

refer to the appropriately authorised officer in accordance with chapter 1.2.9 of the

Food Law Code of Practice (Scotland) and the Feed Law Code of Practice (Great

Britain).


http://www.food.gov.uk/multimedia/pdfs/feedcodeofpractice.pdf


10

Enforcement Guide to Primary Production March 2011

The risk rating that should be applied to these businesses depends on the activities

undertaken:

Businesses engaged in Annex I (primary production) activities only are

subject to the risk rating described in the Food Law Code of Practice

(Scotland), Annex 10 (2% and 25%).

Businesses engaged in Annex II (secondary production) activities only are

subject to the risk rating described in the Food Law Code of Practice

(Scotland) and the Feed Law Code of Practice (Great Britain), Annex 5 (as

appropriate).

The risk rating to be applied to businesses engaged in both primary and

secondary activities will be that which is reflected by the higher risk activity.

However, on grounds of proportionality, those activities which fall within the

scope of primary production need only be inspected in accordance with the

primary production risk rating.

In addition, the Food Standards Agency is working to reduce the burden of

regulation, and therefore the number of inspections on farm. It is recognised that LAs

may carry out primary production inspections at the same time as other inspections

on farm, for example feed hygiene inspections for compliance with Annex II, animal

health inspections and weights and measures inspections. This is acceptable

provided the frequency of the primary production inspection is not less than that

provided for in Annex 10 of the Food Law Code of Practice (Scotland).







11


PART 2: RISK ASSESSMENT – PRIMARY PRODUCTION

FOOD AND FEED

The frequency of primary production food and feed hygiene inspections undertaken

by local authorities will be determined by risk assessment. The risk rating is

described in section A10.5 of the Food Law Code of Practice (Scotland).

Membership of a recognised farm assurance scheme is factored into the risk

assessment as it may help the business to comply with hygiene requirements.

However, the outcome of the inspection and local knowledge will have precedence in

determining the appropriate risk rating for the business.

Officers are encouraged to ask the food/feed business operator for a copy of their

assurance scheme inspection reports. This may be of use to identify problem areas,

but inspections should not be limited to these areas. However, since the report is the

property of the food/feed business operator, it must be recognised that it may not

always be provided.

The following farm assurance schemes were evaluated by the Food Standards

Agency against the requirements of the food hygiene legislation and are currently

considered to meet those requirements.

Assured British Meat (ABM )

Assured British Pigs (ABP)

Assured Chicken Production (ACP)

Assured Combinable Crops Scheme (ACCS)

Assured Produce (AP)

Genesis Quality Assurance (GQA)

Quality Meat Scotland (QMS)

Farm Assured Welsh Livestock (FAWL)

Northern Ireland Beef/Lamb Farm Quality Assured Scheme (NIBLFQAS)

Scottish Quality Cereals (SQC)


12


PART 3: ON FARM INSPECTION AND ENFORCEMENT

1. Notice of Inspection

Article 3.2 of Regulation (EC) No. 882/2004 requires that official controls shall be

carried out without prior notification to the food/feed business operator, except in the

case of audits where prior notification to the food/feed business operator is

necessary. It is the view of the Food Standards Agency that where it is necessary to

inspect records on farm, it is reasonable to provide prior notification. This period

should not be excessive and kept to within 48 hours of the proposed visits, if at all

possible.

2. Bio-Security

Bio-security measures are to be followed and information is available on the

Scottish Government website: -

http://www.sears.scotland.gov.uk/DocumentView.aspx?id=133

http://www.scotland.gov.uk/Publications/2002/11/15800/13887

3. Roles of Local Authority and SGRPID Enforcement

Officers

Both Local Authority officers and Scottish Government Rural Payments and

Inspections Directorate (SGRPID) officers are authorised to carry out food and feed

primary production enforcement.

If a local authority officer has sufficient concerns about the conditions/activities on

farm, that may also have an impact on cross compliance, they should consider

reporting this matter to SGRPID (see Annex 8 for contact details). If a breach is

confirmed by SGRPID to have taken place, they must impose financial penalties. It is

therefore possible that a farm may be subject to enforcement action by both the local

authority and SGRPID.


http://www.sears.scotland.gov.uk/DocumentView.aspx?id=133



SGRPID officers are authorised under Regulation 5(6) of the Food (Hygiene)

Scotland Regulations 2006 and Regulation 16(3) of the Feed (Hygiene and

Enforcement) Scotland Regulations 2005 for the purpose of enforcing primary

production food and feed hygiene measures respectively. SGRPID officers are

authorised to undertake inspections and to serve Hygiene Improvement Notices. If it

is considered that action should be taken which exceeds the authorisation of

SGRPID officers, they should contact the local authorities (either directly or via the

Food Standards Agency).

4. The Inspection and Inspection Checklist and Reports

During the inspection, the officer should establish the scope of their activities and

membership of any assurance schemes. A model form for recording this information

is provided in Annex 4A.

Discussions with the producer should be focussed on the reduction and prevention

of hazards. Annex 4B provides an example checklist which may be used by local

authority officers. The areas marked with an asterix on Annexes 4A, 4B and 4C

are essential (1) for recording the inspection outcomes in the Scottish Primary

Production Official Controls System (SPPOCS) database and (2) for providing the

food or feed business operator with a report following the inspection. A single report,

covering food and feed, and based on Annex 6 of the Food Law Code of Practice

(Scotland) and the Feed Law Code of Practice (Great Britain) must be provided. It

may be provided as a report left on the day of inspection or may be issued

separately at a later date by the Food/Feed Authority.

Annex 4C may be a useful tool in summarising data required for SPPOCS. However,

if the data is contained elsewhere, the completion of this form is optional.

Note that local authorities or liaison groups are free to adapt the forms for their

own use, provided the fields marked with an asterix are retained.

5. On Farm Incidents

The Food Standards Agency Scotland has a contract with the Scottish Agricultural

College (SAC) to investigate on farm incidents in relation to livestock disease, illness

or death. They will carry out post-mortems, provide veterinary advice and liaise with







http://www.food.gov.uk/enforcement/enforcework/feedlawcop/


appropriate bodies as necessary. Examples of such incidents might include sudden

death of livestock caused by elevated levels of lead in their organs as a result of

access to discarded batteries, flaking paint etc or copper poisoning of sheep. Should

an enforcement officer be aware of such an incident, they should contact the Food

Standards Agency.

6. SPPOCS (Scottish Primary Production Official

Controls System) Database

The Food Standards Agency Scotland has developed a database on which primary

production food and feed hygiene inspections are recorded.

The database is used to record primary production inspections by both local

authorities and SGRPID (including the Egg and Poultry Unit) with the facility to attach

reports etc. The information on the database is accessible to both parties, and the

Food Standards Agency. The information gathered at the inspection shall be

recorded on the “event form” which also has the facility to record membership of

assurance schemes and follow-up action. The event form has also been designed to

capture the necessary information which shall be used to inform the outcomes of the

pilot4.

Guidance on the operation of the database has been developed and this has been

made available separately.

4 Operating until spring 2011.


ANNEX 1

ANNEX 1: GLOSSARY

EC European Commission

EPU Egg & Poultry Unit

FBO Food Business Operator

FeBO Feed Business Operator

LA Local authority

PPP Plant Protection Products

RTE Ready to Eat

SAC Scottish Agricultural College

SEPA Scottish Environment Protection

Agency

SG Scottish Government

SGRPID Scottish Government Rural Payments

& Inspections Directorate

SMR Statutory Management Requirement

SOA Sole Occupancy Authority


ANNEX 2

ANNEX 2: LEGAL REQUIREMENTS AND BEST PRACTICE

A. Summary of Requirements

Food –production

livestock Food products

– plant Feed

1. General Food

Law

2. General Facilities

3. Feed Storage and

Handling

4. Fields and

grazings

5. Cleanliness of

animals

6. Water

7. Staff hygiene

8. Pest Control

9. Waste

10. Animal Disease

11. Plant disease

12. Relevant

analysis

13. Additives and

medicines

14. Plant protection

products

15. Packaging of

feed

16. Record keeping

The purpose of a feed /food primary production inspection is to verify compliance with

Regulations (EC) Nos. 852/2004 and 183/2005 (Annexes I) which aim to reduce

contamination of food and feed respectively.

Three case studies have been provided in Annex 3 to this document.



ANNEX 2


2.

3.

3.

4.

5.

B Legal Requirements and Recommended Practice

1. General Food/Feed Law

Aim

The FBO must not place food/feed on the market if it is unsafe. Food is considered to be unsafe if it is

either injurious to health or unfit for human consumption. Feed is considered unsafe if it has an

adverse affect on human or animal health, or makes the food derived from food producing animals

unfit for human consumption. Procedures must be immediately initiated to withdraw the affected

food/feed from the market and inform the competent authorities if it is suspected that it does not meet

food/feed safety requirements.

(i) Check that the FBO/FeBO knows what to do if there is a requirement to withdraw of

affected food and feed from the market place. There is no need to have written

procedures.

(ii) The FBO/FeBO needs to be able to trace goods which have been supplied. Relevant

information should include who the supplier is, date of receipt, quantity, any batch numbers

etc. In addition, they should also be able to trace where their produce has been sent:

name of customer, date of delivery/collection/sale (as relevant), quantity and any batch

details. Existing records such as invoices, delivery notes, receipts etc may provide this

information. There is no need for internal traceability (i.e. the ability to trace which raw

materials were used for the production of the final product).

2. General Facilities

Aim

Control of contamination of primary products. Measures are to be put in place to ensure that facilities

and equipment used for primary production, and associated operations, including transport and

storage, are to be kept clean and where necessary after cleaning, they are to be disinfected. Feed

and food plant products are to be kept clean.

(i) Steadings and sheds should be inspected for cleanliness, to ensure the hygiene of the

produce and control of pest activity. Structures should allow for cleaning to take place, as

far as practical.

ANNEX 2


(ii) The officer should look for evidence of:

The buildings, facilities and equipment being appropriately and regularly cleaned.

Facilities and equipment are to be made of materials that can be effectively cleaned

and disinfected, as necessary. They should be cleaned on a regular basis to

prevent the build up of excessive dirt or muck.

Facilities, equipment, containers, crates, packaging, vehicles and vessels used to

transport or store harvested plant products are being cleaned i.e. free from

contamination that poses a risk to food or feed safety, e.g. animal or bird muck, dirty

water, no visible residues of fuel, oil, pesticides, pest control chemicals, glass,

knives, blades, plasters, wood splinters or metal fragments. There is to be no visible

evidence of pest infestation or mould spoilage.

If vehicles or trailers are used to move primary products to a storage facility, the

officer should be satisfied that they are kept clean and dry. The officer should

determine whether any vehicles or trailers used for one purpose are also used for

other purposes, which could result in cross contamination. If so, the officer should

be satisfied that appropriate cleaning and disinfection takes place.

The design of the store should ensure it is capable of being cleaned. Storage areas

should be properly maintained in order that food/feed is protected from

contamination including contamination from the materials used to construct the

store e.g. concrete walls and floors.

Lights and windows in buildings should be designed or shielded to avoid

contamination of primary products with glass/plastic particles.

In order to prevent the development of mould in storage facilities, it is important that

o Cereals are dried adequately, or treated appropriately, before storage.

o Ingress of moisture to the store is prevented

o Stores are kept cool and dry

ANNEX 2


1.

3. Feed handling and storage

Aim

Feed business operators are to take adequate measures to clean, and where necessary disinfect

facilities, equipment, containers crates, and vehicles used for producing, preparing, grading, storing

and transporting feed. To ensure hygienic production, transport and storage conditions for feed. Feed

equipment designed, constructed and placed in such a way that contamination is minimised.

The officer should consider any risks arising from sources of contamination e.g.

livestock having access to farm buildings or stores. In addition, consideration

should be given to access to material which could cause harm to livestock or

subsequently to human health e.g. ruminants having access to feed intended for

other species which might contain bone meal, seeds, fertilizers, pesticides etc.

The cleaning and, where necessary, disinfection practices associated with feed

storage facilities (e.g. bulk bins) and feeding systems (e.g. chain feeders, troughs,

tubes and pans) should be considered. The risks caused by inadequate cleaning

and potential contamination from cleaning material used should be assessed.

On sites where milling and mixing of feed takes place, the inspection should

determine the source of the ingredients used, including the source and type of any

concentrates or supplements used. Consideration should be given to whether the

feed business operator falls within the scope of Annex II of Regulation (EC) No.

183/2005. Annex 5 of this document provides some examples of such activities.

The officer should check how each ingredient is stored on the site (e.g. in bags or

bulk) and whether there are risks of contamination due to a lack of cleanliness of

storage facilities, moisture, the presence of animals and pests and any other

factors.

On sites where finished feed is bought-in, the inspection should establish whether

storage is in bulk or in bags and assess the risks of contamination, as above. The

officer should be satisfied that the feed is sourced from a registered/approved

supplier and that any supplements provided are also unlikely to lead to

contamination risks. If veterinary medicinal products are used, this must be

recorded (see section 13 below).

Packaging used for the storage of materials produced on-site should be protected

from contamination.



ANNEX 2


1.

2.

3.

4.

4. Use of Fields and Grazing

Aim

Control of contamination of primary products which could arise from the land and fertilisers. Grazing

of pastures and croplands are to be managed to ensure minimal contamination of foods of animal

origin. Where appropriate, an adequate rest period shall be observed before allowing livestock to

graze on pasture, crops and crop residues and between grazing rotations to minimise biological cross

contamination from manure, where such a potential problem exists. The withholding periods for

agricultural chemical applications are observed.

4A. Use of land for grazing

(i) The site selected for grazing should be appropriate for its use, with the history of

previous use taken into consideration to ensure minimising the risk of

contamination. Consideration should also be given to what has been applied to

the land such as composts. Ensure the grazing ban (Regulation 7 of Animal By-

Products (Enforcement) (Scotland) Regulations 2011 has been observed. In

addition, the UK Safe Sludge Matrix should be considered in relation to grazing.

(ii) Grazings should be free from sources of harmful contamination e.g. discarded

batteries, machinery, litter, etc. Pastures and grazings should be managed to

enable the control of harmful weeds e.g. Common Ragwort. See SAC Ragwort

Control Leaflet

4B. Use of land for growing crops

(i) The site selected should be appropriate for its use, with history of previous use

taken into consideration. Officers should establish what steps the FBO/FeBO

has taken to address this requirement.

(ii) Further guidance available:

The UK Safe Sludge Matrix.

FSA Mycotoxin guidance

FSA Manure Guidance

Scottish Code of Practice for Use of Plant Protection Products

http://www.legislation.gov.uk/ssi/2011/171/contents/made


http://www.assuredproduce.co.uk/_code/common/item.asp?id=4033093

http://www.sac.ac.uk/mainrep/pdfs/tn570ragwortpoisoning.pdf

http://www.sac.ac.uk/mainrep/pdfs/tn570ragwortpoisoning.pdf


http://www.food.gov.uk/foodindustry/farmingfood/fusarium/

http://www.food.gov.uk/multimedia/pdfs/manuresguidance.pdf


ANNEX 2


5.

6.

7.

Guidance on the application of animal manures and other fertilisers to growing

crops or land before planting and S co tt ish Go ve rnmen t‟s P reve n tio n

of Environmental Pollution from Agricultural Activity (PEPFAA) Codes.

5. Cleanliness of animals

Aim

Animals going to slaughter and production animals should be kept clean

(i) The buildings in which the livestock are housed should be checked to ensure good

ventilation and drainage.

(ii) The officer should establish whether the farmer has an understanding of the need for

animals to be clean prior to transport for slaughter e.g. by bedding on straw and/or clip and

that transport vehicles (including contractors) have been cleaned and disinfected before

loading.

(iii) For further information on the cleanliness of animals, please refer to FSA Clean

Livestock Guidance

6. Water

Aim

Food Primary Production use potable, or clean, water wherever necessary

Feed Primary Production: use clean water

Good Feeding Practice: drinking water should be of an appropriate quality. Watering equipments

should be designed, constructed and placed to ensure that contamination of water is minimized.

Watering systems shall be cleaned and maintained regularly.

(i) Animals should be prevented from drinking from a contaminated source, as far as

possible.

(ii) The inspection should determine the source of the water supply. If a non-mains supply

is used (e.g. borehole, streams), the officer may need to consider the following:




http://www.food.gov.uk/foodindustry/farmingfood/cleancattleandmeatsafety/

http://www.food.gov.uk/foodindustry/farmingfood/cleancattleandmeatsafety/

ANNEX 2


8.

if the source is suitable for its intended use (consideration given to environmental

and hygiene arrangements),

the design,

the use of any water treatment systems,

whether water quality tests that have been undertaken to establish the safety of

the water.

Consideration should also be given to undertaking a risk assessment on water sources

used on the production holding to ensure water does not pose a risk to food safety.

(iii) The producer should assess the cleanliness of drinking systems and the risk of

water contamination. The officer should check that sources of water are protected from

contamination, as far as practical. Since it is possible that troughs/ water drinkers could

become contaminated, it is important that there is a cleaning regime in place for them.

(iv) Water harvesting systems (e.g. rainwater water collected from building roofs etc.)

should be assessed for suitability of use. Water from such systems is of non-potable

standard unless an appropriate treatment is installed. A risk assessment should be carried

out, particularly where water is used for drinking water for animals, irrigation of ready-to-

eat crops or spraying.

7. Staff - Hygiene and Training/Knowledge

Aim

Ensure that staff are in good health, undergo training on health risks and have the requisite ability,

knowledge and competency.

(i) The ability, knowledge and competency of staff shall be commensurate with their

activities. Adequate training shall be identified, and/or supervision for staff. It is good

practice to keep training records, although not essential.

(ii) Depending on the nature of activities, particular emphasis should be given to the

availability and suitability of hand cleansing and drying facilities. The officer should

ascertain the type and location of facilities provided (e.g. hand wash basins, gel

dispensers, towels etc.) and the range of tasks that staff may be performing as a basis for

ANNEX 2


9.

10.

assessing the suitability, or otherwise, of facilities. The officer should be satisfied that the

facilities in place are being used appropriately by staff on a regular basis.

(iii) Staff, contractors and visitors should be aware of, and follow, basic hygiene principles,

e.g. likely hazards and sources of contamination, importance of personal hygiene, need for

clean hands, clothing and footwear, cleaning and disinfection methods.

(iv) There should be adequate provision of protective clothing and/or equipment, if

necessary.

(v) There must be an understanding that anyone suffering from, or being a carrier of, a

disease likely to be transmitted through food must be prevented from handling ready to eat

(RTE) foods.

(vi) If staff, contractors and visitors handle RTE foods, it is good practice for there to be a

personal hygiene policy that includes the need for personnel to undergo health screening

and to receive induction training in food hygiene or to be supervised.

(vii) The officer may question management and staff to establish whether they are

competent and understand hygiene and food safety requirements e.g. correct use of

animal medicines, pesticides and biocides.

8. Pest Control

Aim

To prevent pests and animals causing hazardous contamination

(i) The producer should be able to describe their pest control procedure. If carried out by a

contractor, the officer should ascertain the frequency of visits and determine if corrective

action has been taken, as appropriate. If carried out by farm staff, the officer should be

satisfied that those involved are competent to carry out the work. The officer may ask to

see any documentary evidence of the inspections undertaken and the products used.

(ii) The inspection should include sheds, stores and any feed mixing areas. These should

be assessed to determine whether the construction and maintenance is suitable for the

exclusion, as far as possible, of animals and pests, including wild birds, rodents and

domestic animals, if this is deemed necessary to protect food/feed from contamination.

ANNEX 2


Buildings should be inspected for gaps and holes which would allow entry, and for

evidence of pest activity.

(iii) In order to minimise the number of harbourages for pests, the inspection should verify

that areas inside and around buildings are kept clean and tidy and that any vegetation

around the buildings is kept low at all times of the year, if practical to do so.

(iv) The officer should verify that conditions within the buildings, and surrounding areas, do

not contribute to a potential pest infestation:

Muck, dirt, spoiled feed and waste should be removed regularly to minimise and

avoid attracting flies, birds or rodents.

All areas should be kept tidy.

Harbourage points such as overgrown areas or redundant scrap metal should be

removed

Feed/litter spillages should be cleared inside and outside building.

Access of pests and pets to growing crops should be minimised, as much as

possible by fencing, netting etc,

(v) The officer should identify if there is any evidence of damage to food/feed by vermin.

(vi) The farmer should ensure that pesticides are not accessible to the livestock at any

time. Bait boxes, where used, should be checked for spillage.

(vii) Where pets are present on farms, they must not present a risk of contamination to the

food or feed. They must be excluded from feed/food storage and production areas, where

possible.

ANNEX 2


11.

12.

9. Waste and Hazardous Substances

Aim

To store and handle waste and hazardous substances, separately and securely, so as to prevent

contamination

Farmers have duty of care to look after waste. Waste must be stored and handled safely

and securely to prevent misuse or contamination. The waste should not be kept for long

periods of time as it increases risk of contamination.

9A. General Waste

(i) If using containers for storing waste, they should be good condition and labelled. Any

old labelling should be removed when re-using containers. Clear instruction should be

available to staff on how to store and dispose of waste and how to deal with spillages.

(ii) Any liquid waste should be prevented from escaping into drains, watercourses or

surrounding ground.

(iii) Consideration should be given to how waste is transported within the business.

Farmers need to ensure that waste is transported in suitable containers and vehicles

without causing contamination.

(iv) Animals should be prevented from having access to waste. Appropriate storage and

disposal of general household waste should be in place.

(v) FBOs/FeBOs should ensure that contractors collecting waste are registered with an

appropriate body for transferring waste. Waste transfer notes should be kept for two years.

(vi) Some types of waste generated on farm, which may be harmful to human health or

environment are classified as special waste and require additional controls. Special waste

includes: animal health products, pesticides and herbicides, chemical waste, solvents,

waste oil, asbestos, lead acid batteries, electrical equipment containing hazardous

components, fluorescent light bulbs and smoke canisters such as empty rabbit, mole or rat

poison containers which contain gassing compounds such as aluminium phosphide, empty

oil containers (other than of edible oil). Special waste must go to a facility which has

licence for dealing with such waste. Special Waste Consignment note needs to be

completed and kept for 3 years.

ANNEX 2


9B. Animal By-Products

(i) The officer should be satisfied that dead animals are removed through an approved

route. Any dead animals awaiting disposal should be stored in a way that will not allow

potential contaminants to spread. Any incinerators used for burning carcasses have to be

approved by Animal Health. On-farm burial is permitted in selected areas in Scotland, but

farmers carrying out on-farm burial have to observe rules applicable to them e.g.

appropriate distance from a water course. See section 10 of S G‟s P reve n tio n of

Environmental Pollution from Agricultural Activity (PEPFAA) Codes.

(ii) Disposal of all animal carcasses must be recorded and a record kept for two years.

(iii) The officer may ask to see mortality records and evidence of carcass disposal

methods

e.g. agreements in place for off-site disposal. The Animal By-Products (Enforcement)

(Scotland) Regulations 2011 sets out requirements for the storage and disposal of

carcasses.

(iv) Slurry and manure for use on farmers own land is not classified as waste. Slurry

and manure originating from other farms should be treated as waste. If any manure,

slurry, etc is stored on site, the officer should be satisfied that it is not likely to cause a

hygiene or disease risk and that animals are prevented from having access to them.

SEPA is the enforcing authority for The Sludge (Use in Agriculture) Regulations 1989

(as amended). The Food Standards Agency considers that the application of sewage

sludge to agricultural land should not present any unacceptable risks to food safety,

provided that it is carried out in compliance with the statutory requirements and the

provisions of the Safe Sludge Matrix (see below).

(v) A range of industrial wastes and compost originating from recycling activities can be

applied to agricultural land. Any sewage sludge has to be treated before being applied to

land. Use of raw (untreated) sewage sludge on agricultural land is not permitted. Abattoir

waste (muck and manure from lairage, and blood and gut content) can be spread to

agricultural land subject to specific conditions.

(vi) Further information can be found in the

The UK Safe Sludge Matrix

Guidance on the application of animal manures and other fertilisers to growing

crops or land before planting and SG‟s P reve n tio n of En viro n m en ta l P o

llu tio n f rom Agricultural Activity (PEPFAA) Codes.

Scottish Code of Practice for Using Plant Protection Products.










ANNEX 2


13.

14.

15.

http://www.sepa.org.uk/waste/waste_regulation/agricultural_waste.aspx

(SEPA Agricultural Waste FAQ)

http://farmwastesc.netregs.gov.uk/default.aspx

For consumer and industry advice on the use of pesticides, further information can

be found at: http://www.food.gov.uk/safereating/chemsafe/pesticides/

10. Zoonotic Disease

Aim

To prevent the introduction and spread of contagious diseases transmissible to humans through food,

including taking precautionary measures when introducing new animals and reporting suspected

outbreaks of such diseases.

(i) Animals should be kept in conditions that ensure their health and welfare, therefore

limiting the potential for zoonotic diseases. It is good practice, although not required, for

the farm to have in place an Animal Health Plan detailing preventative measures for

disease control, dealing with the outbreak of disease etc

(ii) The outbreak of zoonotic disease may be affected by the condition of the buildings and

facilities and reference should be made to section 2 within this annex.

(iii) The officer should satisfy himself/herself that the farmer is aware what actions are to

be taken in the following circumstances:

When introducing new animals on the holding statutory standstill or separation

rules apply.

The veterinary surgeon should be contacted when there is a suspicion that an

animal is sick, and veterinary advice should be followed.

Any results of analysis, which may have an effect on food safety, should be acted

upon

Any outbreaks of notifiable diseases should be reported to the appropriate body –

Animal Health or the Local Authority.

http://www.sepa.org.uk/waste/waste_regulation/agricultural_waste.aspx

http://farmwastesc.netregs.gov.uk/default.aspx

http://www.food.gov.uk/safereating/chemsafe/pesticides/

ANNEX 2


16.

17.

11. Plant Disease

Aim

To control the hazards relating to plant health that have implications for human health and feed safety

11A. Fusarium

(i) Cereals infected with fusarium can produce toxic mycotoxins, which can affect human

and animal health when ingested. Fusarium mycotoxin levels are quite low in Scotland

however they have increased during recent summers.

http://www.food.gov.uk/multimedia/pdfs/fusariumcop.pdf

(ii) Officers should ensure that farmers are aware of the measures that should be in place

to prevent the production of fusarium mycotoxins. The FBO or FeBO should be aware of

appropriate preventive measures that can be taken to manage fusarium contamination and

the circumstances in which they should be employed.

FSA Managing mycotoxin risk guidance:


11B. Ergot

(i) Ergot which affects cereals (mainly rye, wheat, barley, triticale, rarely oats, sometimes

grasses), can act as a host to fungus Claviceps. Each sclerotium contains high

concentrations of alkaloids, which are highly toxic when ingested by humans or animals.

(ii) Fields or field verges where ergot has been identified, must be managed to reduce

ergot infestation the following growing season (e.g. deep ploughing). Batches of grain with

ergot present can be used for food/feed provided that effective screening is applied to

remove all ergot. However, in practice grain with ergot present is rejected for food/feed

use.

Further info: http://www.sac.ac.uk/consulting/services/c-e/cropclinic/clinic/diseases/ergot

http://www.food.gov.uk/multimedia/pdfs/fusariumcop.pdf


http://www.sac.ac.uk/consulting/services/c-e/cropclinic/clinic/diseases/ergot

ANNEX 2


12. Relevant analysis

Aim

To take account of the results of any relevant analyses carried out on samples taken from

animals/plants or other samples that have importance to feed safety and/or human health

(i) The officer should ascertain if any results of analysis are available which relate to the

production of feed or food. Where analytical results are available, these should be

examined.

(ii) The officer should verify that appropriate action has been taken when results of

analysis indicates a risk to food or feed safety.

(iii) Examples of analyses having importance to food/feed hygiene or safety include:

Water sampling - if analysis reveals that water may pose risk to food safety, the

water supply should be reviewed. Remedial work should be carried out to remove

or reduce contamination or an alternative source should be used.

Ergot – see above

Salmonella - Salmonellosis is a serious disease and livestock may carry bacteria,

which can enter food chain through contaminated carcasses. When salmonella

presence has been confirmed on farm, appropriate steps have to be taken to

reduce the risk of spreading and cross-contamination. Infection survives in dirty

bedding, equipment and buildings and staff in contact with infected areas can

transmit bacteria to non-infected areas. Where salmonella has been confirmed the

producer needs to demonstrate that:

o he has taken steps to prevent spread of infection;

o affected areas have been cleaned and disinfected, including equipment

and tools;

o good personal hygiene is in place;

o biosecurity measures implemented.

Special rules apply for control of Salmonella in laying flocks. For further information,

refer to Code of Practice to Control Salmonella in Feeds

http://www.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/zoonoses/documents/reports/salmonella-feed-cop.PDF

ANNEX 2


13. Additives and medicines

Aim

To use feed additives, and premixtures of feed additives, and veterinary medicinal products correctly,

as required by relevant legislation

(i) The officer should ascertain if any livestock currently on site has received any

veterinary medicine. If so, the officer should be satisfied that there has been appropriate

veterinary input and that farm personnel involved in administration have adequate

experience and suitable knowledge of procedures and withdrawal periods. Only

authorised products obtained from a registered supplier may be used.

(ii) Treated animals must be identified and a record kept of dates of administration of the

treatment i.e. veterinary medicines or other treatments, and withdrawal periods. Medicine

records for food producing animals are to be kept for at least five years (a requirement of

The Veterinary Medicines Regulations 2009) are to be kept for five years.

(iii) Medicines must be stored safely and securely and medicated feeds kept separate from

other feeds and clearly labelled.

(iv) Farmers using silage additives must follow the instruction for use and rates of

incorporation. They should retain records relating to the nature, quantity and source of the

additives.

(v) Farmers using feed additives, other than silage additives, must comply with Annex II of

183/2005 and have HACCP in place.

Additional information is available in Responsible Use of Medicines in Agriculture Alliance

(RUMA) guidelines

The list of registered feed additives is found at:

http://ec.europa.eu/food/food/animalnutrition/feedadditives/comm_register_feed_additives

_1831-03.pdf

http://www.legislation.gov.uk/uksi/2009/2297/contents/made

http://www.ruma.org.uk/farm.htm

http://www.ruma.org.uk/farm.htm

http://ec.europa.eu/food/food/animalnutrition/feedadditives/comm_register_feed_additives_1831-03.pdf

http://ec.europa.eu/food/food/animalnutrition/feedadditives/comm_register_feed_additives_1831-03.pdf

ANNEX 2


1.

2.

14. Plant protection products (PPP)

Aim

To use plant protection products and biocides correctly, as required by the relevant legislation

(i) Producers are obliged to use PPP and biocides safely and in accordance with law.

Pesticide applications should be carried out at the right time, at the correct rate and in the

correct manner using the correct product. Only products approved at the time of

application can be used. Operators carrying out pesticide applications must be

appropriately trained and/or qualified. Any directions of use included in the product‟s label

should be followed.

(ii) The officer should satisfy himself/herself that the recommendations and legal

requirements on rates of use/ harvest intervals are being followed and that applications of

all PPP are recorded. It is recommended that those records are kept for at least 3 years.

(iii) PPP are to be stored correctly. Only approved products should be present on premises

in the original container with the label. Health and Safety Guidance on storing pesticides

for farmers and other professional users: http://www.hse.gov.uk/pubns/ais16.pdf

(iv) rther information can be found at:

http://www.pesticides.gov.uk/approvals.asp?id=871

Code of Practice for Using Plant Protection Products in Scotland.

Codes of Good Agricultural Practice (UK).

FSA Pesticide Guidance

http://www.hse.gov.uk/pubns/ais16.pdf

http://www.pesticides.gov.uk/approvals.asp?id=871

http://www.scotland.gov.uk/Resource/Doc/161422/0043816.pdf

http://www.defra.gov.uk/foodfarm/landmanage/cogap/documents/cogap090202.pdf

http://www.food.gov.uk/safereating/chemsafe/pesticides/

ANNEX 2


1.

2.

1.

2.

3.

15. Packaging

Aim

To ensure that packaging materials are not a source of hazardous contamination to feed

(i) Animal feed must be free from packaging. The officer should ascertain if the livestock

farm is using feed derived from co-products of food. If so, the co-products must be free

from contamination caused by remnants of packaging.

(ii) If bags are used for the storage of feed on farm, consideration should be given to the

previous use of the bag. Bags, sacks or containers which were used previously for other

purposes can be re-used provided they are cleaned adequately to prevent contamination.

Old labelling/markings may lead to confusion or mis-use and should be removed. Some

products pose higher risk (treated grain, some fertilisers and chemicals) and residues are

difficult to remove. Bag and containers containing such products should not be re-used for

feed.

(iii) The officer should check the storage area and the condition of the packaging. Gross

contamination of packaging can lead to contamination. Such packaging should be

removed if possible.

16. Record Keeping

Aim

To keep and retain records in relation to the control of hazards, in an appropriate manner, for an

appropriate period, commensurate with the nature and size of the business. This information should

be available to the authorities and customers, on request

Reference should be made to the guidance document:

“Guidance for Farmers on Record Keeping Requirements of Annex I of EC Feed Hygiene

Regulation (183/2005) and Annex I of EC Food Hygiene Regulation (852/2004)”

http://www.food.gov.uk/scotland/regsscotland/regsguidscot/feedfoodrecordkeepingreqssco

t

In addition to statutory record keeping under existing Community or domestic legislation,

appropriate records should be kept and maintained, proportionate to the nature and size of

the business.

http://www.food.gov.uk/scotland/regsscotland/regsguidscot/feedfoodrecordkeepingreqsscot

http://www.food.gov.uk/scotland/regsscotland/regsguidscot/feedfoodrecordkeepingreqsscot

ANNEX 2


Livestock

(i) An officer may ask to see any of the following records during the inspection:-

Details of the nature and origin of feed fed to the livestock (e.g. feed supplier and

specification as indicated on delivery note, invoice or label)

Veterinary medicinal products used, the date(s) of administration and any

withdrawal periods

Information on the occurrence of diseases that may affect the safety of the products

of animal origin (e.g. relevant veterinary reports)

The results of any analyses carried out on animals or other samples that have

importance for human health

Any relevant reports on checks carried out on animals or products of animal origin

Records relating to waste disposal

Arable


Use and disposal of plant protection products and biocides

Information on the occurrence of pests or diseases that may affect the safety of the

products of plant origin

The results of any analyses carried out on plants or other samples that have

importance for human health

Any relevant reports on checks carried out on plants or products of plant origin

Feed


Any use of plant protection products and biocides

Information on the occurrence of pests or diseases that may affect the safety of

feed

ANNEX 2


The results of any analyses carried out on primary products or other samples that

have importance for feed safety

The source and quantity of each input of feed and the destination and quantity for

each output of feed.


ANNEX 3

ANNEX 3: CASE STUDIES

Action taken by enforcement officers should be in line with the Enforcement Policy of the

local authority. The Food and Feed Law Codes of Practice state that food or feed

authorities should ensure that enforcement action taken by their authorised officers is

reasonable, proportionate and consistent with good practice. Any enforcement action

should be carried out by an appropriately authorised officer.

Except where circumstances indicate a significant risk, officers should operate a graduated

and educative approach starting at the bottom of the pyramid i.e. advice/education and

informal action and only move to more formal action where the informal does not achieve

the desired effect.

The decision to take formal action will depend on whether it is considered proportionate to

do so, if informal action is deemed inadequate or there is a history of non-compliance. The

FBO/FeBO may agree to take voluntary action. If an informal approach is adopted, then

correspondence should contain sufficient information to adequately inform the FBO/FeBO

of the action they are required to take and the reasons why. It should be discussed and, if

possible, agreed with the FBO/FeBO.

It is important to note that the Food and the Feed Regulations are not prescriptive and that

there may be more than one way to address the requirements of the Regulations. It will be

the responsibility of the FBO/FeBO to demonstrate that the measures that they have put in

place are adequate to protect the feed/food from contamination.

.


ANNEX 3

Case Study 1 – Contaminated Bread Meal During an inspection of a store on a livestock farm, an officer notices a container of bread

meal with a large amount of visible packaging. This bread meal is bought in from a local

supplier.

1. What are the concerns?

Bread meal showing contamination with wrapper and button

2. Key Legal Requirements

EC Regulation 183/2005, Annex I

Feed business operators shall meet the obligations ........... by complying with appropriate Community and national legislative provisions relating to the control of hazards, including: (i) measures to control hazardous contamination such as that arising from the ........ handling and disposal of waste,

Where appropriate, feed business operators shall take adequate measures, in particular: (f) to ensure that packaging materials are not a source of hazardous contamination of feed;


ANNEX 3


Notwithstanding the general duty laid down in paragraph 2, food business operators are to comply with appropriate Community and national legislative provisions relating to the control of hazards in primary production and associated operations, including: (a) measures to control contamination arising from ............ feed, fertilisers, veterinary medicinal products, ....................

Food business operators rearing, harvesting or hunting animals or producing primary products of animal origin are to take adequate measures, as appropriate: (a) to keep any facilities used in connection with primary production and associated operations, including facilities used to store and handle feed, clean and, where necessary after cleaning, to disinfect them in an appropriate manner;

3. Suggested course of action

The bread meal must not be fed to animals. Packaging in feed is not permitted.

The feed materials should isolated and detained to prevent the feed being used.

The FeBO may agree to voluntarily surrender the feed.

Steps are to be taken to identify the supplier of the feed and where the

contamination occurred (at the supplier or on farm).

If the contamination originates on the farm, action must be taken to identify and

isolate the source of that contamination. Remove the feed and store elsewhere until

the source of contamination has been addressed. Repair and maintain equipment, if

necessary, or review of process.

Depending on the nature and severity of the contamination consideration should be

given to destruction of feed or re-processing. Can re-processing adequately reduce

the level of contamination?

A revisit may be appropriate to determine if the necessary action related to

equipment or processes on farm has been effective.

If necessary, consider prohibition procedures if an informal approach is deemed to

be inadequate.


ANNEX 3

Case Study 2 – Feed Store

The following feed storage area was found on a mixed livestock farm: feed storage bays

separated by old painted doors. Livestock have access to the area.

1. What are the concerns?

The doors used to divide the storage space are painted. It is not clear what sort of paint

has been used for doors. Lead paint poses a particular hazard to calves.

There could be a risk of cross contamination in the store between feeds, for example:

medicated and non-medicated feed,

feed materials and additives/premixtures containing additives,

feed materials suitable for one species contaminating feed which may be hazardous

to other species (e.g. sheep feed contaminated with cattle feed containing copper

supplementation)

ANNEX 3

nforcement Guide to Primary Production 39 March 2011

The contamination may occur as a result of mixing in situ, contamination from the shovel

or any other equipment.

Consideration needs to be given to what else is stored here and whether feed/other

materials have been adequately identified.



Feed business operators responsible for primary production of feed shall ensure that operations are managed and carried out in such a way as to prevent, eliminate or minimise hazards with the potential to compromise feed safety.

Feed business operators shall ensure, as far as possible, that primary products produced, prepared, cleaned, packed, stored and transported under their responsibility are protected against contamination and spoilage.

Where appropriate, feed business operators shall take adequate measures, in particular: to keep clean and, where necessary after cleaning, to disinfect in an appropriate manner, facilities, equipment, containers, crates and vehicles used for producing, preparing, grading, packing, storing and transporting feed;

to ensure, where necessary, hygienic production, transport and storage conditions for, and the cleanliness of, feed; to prevent, as far as possible, animals and pests from causing hazardous contamination;

Feed business operators shall keep records relating to measures put in place to control hazards, in an appropriate manner and for an appropriate period, commensurate with the nature and size of the feed business. Feed business operators must make relevant information contained in these records available to the competent authority.


............ food business operators are to comply with appropriate Community and national legislative provisions relating to the control of hazards in primary production and associated operations, including: (a) measures to control contamination arising from .......... feed, fertilisers, veterinary medicinal products, plant protection products and biocides and the storage, handling and disposal of waste;

EC Regulation 178/2002, Article 18(1)

The traceability of food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution.

E

ANNEX 3


3. Suggested course of action

A number of questions must be asked to establish if there is a breach.

Feed

Consideration should be given to the detention of the feed unless the FeBO agrees

to voluntary surrender it.

Consideration needs to be given to other feed/items being stored in the area. Is

there any risk of contamination from one to the other?

Are the items being stored adequately identified or labelled? Are records kept?

Tools

There should be a cleaning regime in place for the tools to ensure there is no risk of

cross contamination, or have dedicated tools or equipment.

It would be good practice to have a label, or other means of identification, on

equipment.

Door

Lead paint is a hazard, particularly to young cattle. Cattle must be denied access to

feed store and should not be able to access the lead paint on the door. Flaking

paint could lead to contamination of feed.

If the door is painted with lead paint, the door or paint should be replaced.

ANNEX 3


Case Study 3 – Fresh Produce (reproduced from training courses 2010/11)

1. Scenario

Geoff Brownlie is a traditional tenant farmer. His holding is small (22 acres in total) with

9.5 acres split evenly between two different fields exclusively dedicated to strawberries¹.

The farm uses polythene tunnels to maximise the fruit-producing interval for the crop.

Picking season is May - October.

There are a core number of permanent, year-round employees. The majority of fruit

pickers are employed seasonally, mostly students and overseas workers. Some workers

return for more than one year. There is not a formal interview process for seasonal staff,

but the farmer does have a basic questionnaire to assess suitability of staff². He provides

workers with boots ³. The farm allows members of the public⁴ to pick fruit for themselves.

There are two field toilets5 provided and a drinking water tap5. There are two hand-

washing stations⁵ provided.

Two years ago the farm sunk a borehole⁶ in response to flood-related problems with the

mains and river water supplies.

There is generally a single application of manure made before planting. The manure

applied is in the form of composted farmyard manure⁷ and is a mix of material from horses,

pigs and cattle⁸ manure provided from a neighbour‟s farm. The manure is composted using

a windrow-style composting system with defined turning and watering (borehole water)

intervals. This is carried out on site and then composted in an outbuilding nearby⁹.

Irrigation water is taken from the farm borehole¹⁰. Water is applied by drip feed from soil-

borne¹¹ hoses. The acceptability criteria used by the farm is determined by the supplier

codes of practice for one of their major retailers.

Fruit is picked by hand¹² into plastic packs¹³ that are used for display by the retailers he

supplies. There is no washing of the crop prior to packing¹⁴.

Once harvested, the fruit is transported via trailer¹⁵ to a nearby store room where they are

cooled using refrigerated air which is forced by fan¹⁶ through crates stacked with berries.

They are then distributed using a commercial distributor in temperature controlled vans¹⁷.

ANNEX 3



EC Regulation 183/2005, Annex I As far as possible, food business operators are to ensure that primary products are

protected against contamination, having regard to any processing that primary products will subsequently undergo.

Notwithstanding the general duty laid down in paragraph 2, food business operators are to comply with appropriate Community and national legislative provisions relating to the control of hazards in primary production and associated operations, including:

(a) measures to control contamination arising from the air, soil, water, feed , fertilisers, veterinary medicinal products, plant protection products and biocides and the storage, handling and disposal of waste;

Food business operators producing or harvesting plant products are to take adequate measures, as appropriate:

(a) to keep clean and, where necessary after cleaning, to disinfect, in an appropriate manner, facilities, equipment, containers, crates, vehicles and vessels;

(b) to ensure, where necessary, hygienic production, transport and storage conditions for, and the cleanliness of, plant products;

(c) to use potable water, or clean water, whenever necessary to prevent contamination;

(d) to ensure that staff handling foodstuffs are in good health and undergo training on health risks;

(e) as far as possible to prevent animals and pests from causing contamination;

(f) to store and handle wastes and hazardous substances so as to prevent contamination;

(g) to take account of the results of any relevant analyses carried out on samples taken from plants or other samples that have importance to human health; and

(h) to use plant protection products and biocides correctly, as required by the relevant legislation.

ANNEX 3


3. Suggested Course of Action

1. Depending on culture system the risk associated with these is that the fruit is low to the

ground – risk from soil and irrigation water contamination. They are also accessible to

vermin. A control can be to grow in raised beds. The poly-tunnels will protect from bird

droppings and contamination from heavy rainfall and the splash back from the soil

associated with this

2. Risk from workers. Does the farmer include a health questionnaire for all staff

(seasonal and permanent)? Does he have an exclusion policy if they contract an enteric

illness? Does he have cleanliness standards for staff? Are all his staff trained in food

safety and hygienic production? Staff should be trained and/or supervised in accordance

with their activities, for example provided with rules to be applied relating their activities.

3. Risks from unclean and inappropriately handled Personal Protective Equipment (PPE).

Are there facilities for boot cleaning and facilities for glove disposal and replacement? If

so, these should be located at a suitable point in the field. Staff wearing their own clothes

on to a site could be a risk. The farmer could provide coveralls and ensure these are not

taken home and are regularly laundered. The farmer could also supply hairnets in fruit

storage areas.

4. Visitors to the site should also be vetted with a health questionnaire. They could be

provided with PPE and asked to wash hands before entering the site. Further controls

could be introduced by asking the pickers to not eat the fruit as they go or by having a field

specifically for pick your own. Are there facilities for boot cleaning? Pets should not be

permitted to enter picking areas.

5. Waste from toilets, drinking facilities and washing station can be a risk, which can be

controlled by situating them a reasonable and suitable distance away from the crops and

having a reliable company service and maintain them. Care should be taken to ensure that

drainage will not cause contamination. Specific care should be taken when emptying

portable toilets.

6. Risk from contamination from run-off, flooding and leaching. These can be minimised

by ensuring the borehole is of a suitable depth, is lined and that steps are taken to avoid

contamination from run-off and other land practices.

7. Risk from inadequately composted farmyard manure. How does the famer ensure that

it is correctly carried out? What parameters does he monitor during the composting

procedure?

ANNEX 3


8. Risk of pathogens in animal faeces. The farmer could check with the provider that his

animals are not suffering from any known disease (ask to see vet reports/results if

necessary). This also gives an insight to neighbouring land use. How does the farmer

protect his land from the animals producing the manure? Does he have adequate

fencing? Is his farm at risk from run-off and does he consider the activities of the

neighbouring farm before harvesting?

9. Risk of contamination by leakage of manure and contamination by pests/vermin. Is the

storage area secure, clean and maintained? Is there pest control in operation?

10. Risk of contamination through irrigation water. Is the farmer satisfied that the water is

of a minimum clean standard?

11. Timing and application of irrigation water is a risk. Drip feed irrigation is good for

strawberries but care will need to be taken to ensure that the source of irrigation water is

clean, and the timing of irrigation with respect to harvesting should also be considered.

The equipment should be clean and in good condition to avoid leaks and contact with fruit.

12. Risk of contamination from workers. Is unsuitable fruit separated and disposed of

properly?

13. Risk of damage to produce and contamination from packaging. Are the packs suitable

for use and clean? Badly designed packaging could damage the fruit and increase the

chances of contamination. In this case, they are single use so should be clean, but the

supplier should be reliable and the farmer could ask for documentation indicating whether

they are food grade etc. The holes in the packaging should allow the cooling air to

penetrate quickly into the crop. The primary purpose of chilling is to prolong shelf life as

much as possible although it will also prevent proliferation of enteric pathogens on the

surface of the fruit.

14. Since no washing is being done here, the farmer would need to ensure that all

previous stages in the production were controlled and produced using good agricultural

practices.

15. Risk of contamination from trailer. Is the trailer only used for transport of strawberries

or similar products? Is it clean? Does it provide shade for the strawberries to protect them

from heat/sun/birds etc?

16. Cross contamination risks. Is the storage facility clean and protected from pests and

other sources of contamination? Besides controlling vermin, other pests such as flies

should be controlled. Is the cooling equipment clean and how does the producer know that

the correct temperatures are being achieved?

ANNEX 3


17. Cross contamination risks. Are the vans clean and only used for the transportation of

his strawberries or similar products? If multiple loads, is there adequate segregation

between the products and have steps been taken to minimise cross contamination risks?

Does the transport company monitor the temperature in the vans and have a correction

procedure in place if the temperature rises?


ANNEX 4A

ANNEX 4A: BUSINESS DETAILS & INSPECTIONS SUMMARY

Primary Production Food and Feed Hygiene Inspection:

Regulation (EC) No. 852/2004, on the hygiene of foodstuffs

Regulation (EC) No. 183/2005, laying down requirements for feed hygiene

NOTE: Fields marked with * are mandatory and are required either for the completion of SPPOCS or of the

report, as required by Annex 6 to the Food and Feed Law Codes of Practice (Intervention Report)

*Officer Name: *Security & Access

*Date and time of

visit:

*FARM/TRADING

NAME: *Farm Assurance

Scheme(s) and what

they apply to:

*NAME AND

POSITION OF

PERSON SEEN:

*ADDRESS: Any Linked Premises/

SOA/Grazing or other

associated holdings?

*TEL NO.

MOBILE NO. Seasonal business?

Provide details

Email/website: Unable to carry out

inspection (reason):

*Holding Number

(CPH) LA Reference number

Reason for Visit

(tick):

Routine Complaint Revisit Trader

Request

Home Authority

Referral

Other

Date of last visit: Risk rating:




ANNEX 4A

PRIMARY PRODUCTION ACTIVITIES

*Premises Type Tick

Below

Comments

Livestock

Arable

Horticulture/Vegetable growers

Mixed – predominately livestock

Mixed – predominately arable

Mixed – predominately

horticulture

Other (name)

Areas inspected

Documents/records examined

Key points, discussed during inspection

Action to be taken by local authority

ANNEX 4A


NON-PRIMARY PRODUCTION

Please provide details of any non-primary production activities taking place on farm:

COMMENTS

Please provide any other comments:

ANNEX 4B


ANNEX 4B: CHECKLIST




× n/a Observations

1. General Food Law Knowledge of product withdrawal

procedures

Traceability in place – from suppliers Traceability in place – to customers 2. General Facilities Structures and equipment clean: free

from contamination (foreign materials,

muck etc)

Construction and design allows for

cleaning to take place

Vehicles clean Storage areas clean and dry Lights and windows shielded 3.Feed Storage

Feed storage – cleaning &

disinfection procedures in place

Do livestock have access to these

areas?

\is there any risk of contamination

from non-feed ingredients e.g.

medicines, plant protection products?

4. Fields and Grazing A. For grazing

Has a risk assessment been carried

out with regards to previous use of

field?

Has grazing ban been observed? Evidence of contamination?

B. For growing crops

Has a risk assessment been carried

out with regards to previous use of

field?




ANNEX 4B

x n/a Observations

5. Cleanliness of Animals Clean environment – good ventilation

and drainage

Understanding about need for clean

livestock prior to slaughter

Evidence of dirty animals

6. Water Source of water supply – private or

public

Has a risk assessment of the water

source been done?

Cleanliness of drinking water systems Water harvesting system in use? Has

a risk assessment been done?

7. Staff Hygiene and

Training/Knowledge

Hand washing/cleansing facilities Knowledge of hygiene principles Protective clothing Understanding of staff exclusion Adequate training/supervision For RTE foods – personal hygiene

policy?

Staff and management competent

8. Pest Control Evidence of pests / animals Condition of buildings and

maintenance – sufficient to exclude

pests?

Areas around buildings clear Areas clean and tidy to prevent pests Pest control contractor used? If internal pest management system

used – is it effective? Are staff

competent?

Contamination risk from bait boxes? Cats used for rodent control? Do cats

present a risk by having access to

produce stores etc


ANNEX 4B

x n/a Observations

9. Waste and Hazardous

Substances

A. General Waste

Waste stored/handled safely &

securely

Adequately labeled waste containers Liquid waste – is it secured? Does transportation of waste around

Farm prevent/reduce risk of

contamination?

Is special waste disposed through an

Approved route. Are records

available?

Are waste contractors licensed? B. Animal By-Products

Is disposal of dead animals

appropriate and recorded?

Is slurry and manure stored

appropriately?

If compost/sewage sludge used on

farm, is it stored and used

appropriately? Are conditions of use

met? Are records kept?

10. Zoonotic Disease Are the conditions suitable for

preventing or reducing the risk of

zoonotic disease?

Is there evidence that veterinary

advice followed?

Is there knowledge that notifiable

disease must be reported?

11. Plant Disease Are farmers aware of the measures

that need to be taken to prevent

fusarium and ergot?

12. Relevant Analysis Have any samples been taken that

are relevant for food/feed safety and

has appropriate action been taken?

13. Additives and Medicines Correct use of vet medicines and

withdrawal periods observed?

Are the products registered and from

a registered supplier?


ANNEX 4B

x n/a Observations

Are treated animals identified? Are medicines and medicated feed

kept separate and labelled?

14. Plant Protection products Correct use of plant protection

products?

Are plant protection products kept

separate and labelled?

15. Packaging of Feed Are co-products free from

contamination?

Are container/bags clean and

appropriately labelled?

Is the condition and storage of

packaging suitable?

Is the condition of re-used packaging

suitable?

16. Record keeping Livestock Nature and origin of feed records Vet medicines usage and withdrawal

periods

Disease occurrence that affects food Analysis reports / results Waste disposal records Application of organic

fertilizers/composts etc to pastures

Other relevant records Are records easily retrievable and in

an appropriate manner?

Arable Use & disposal of PPP and biocides Occurance of disease and pests Analysis reports / results Pest control Other relevant records Are records easily retrievable and in


Feed Nature and origin of feed records Use & disposal of PPP and biocides Occurence of disease and pests Analysis reports / results


ANNEX 4B

Other relevant records Are records easily retrievable and in


*Officer Name (in capitals):………………………………………………………………….

*Signature:…………………………………….. *Date:……./……../……

*Designation of Authorised Officer:…………………………………………………………

*Contact details of Authorised Officer:

……………………………………………….

……………………………………………….

……………………………………………….

……………………………………………….

*In case of dispute, please contact:

……………………………………………….

……………………………………………….

……………………………………………….

……………………………………………….

Local Authority name and address:

……………………………………………….……………………………………………….

……………………………………………….……………………………………………….


ANNEX 4C

ANNEX 4C: INSPECTION OUTCOME SUMMARY




NOTE: Fields marked with * are mandatory and are required for the completion of SPPOCS

Inspection Outcome Summary – Food Hygiene

Criteria Possible categories Tick the category

that applies

*Annex I compliance Not applicable

Not yet determined

Pass

Substantially meets requirements

Fail

Serious failure in compliance

*Other intelligence Positive

Negative

Nil

*Risk rating 2%

25%

*Report to business date




ANNEX 4C

Inspection Outcome Summary – Feed Hygiene

Criteria Possible categories Tick the category

that applies

*Annex I compliance Not applicable

Not yet determined

Pass


Fail


*Annex III compliance Not applicable

Not yet determined

Pass


Fail


*Other intelligence Positive

Negative

Nil

*Risk rating 2%

25%

*Report to business date

ANNEX 56


ANNEX 5: EXAMPLES OF ACTIVITIES THAT WOULD FALL

WITHIN THE SCOPE OF ANNEX II OF REGULATION (EC) NO.

183/2005

Annex II and procedures based on HACCP apply to these activities:

Convection drying (using gas or oil) of cereals

Mixing of feed using additives5 (except silage additives), and pre-mixtures

containing such additives, even if for use on own holding. This would not include

complementary feeds and complementary mineral feeds which are within the scope

of Annex I.

Farms mixing feeds with non-antibiotic growth promoters, coccidiostats and

histomonostats (including complementary feeds, containing these additives). These

are subject to approval by the Animal Medicines Inspectorate (AMI), which is part of

the Veterinary Medicines Directorate.

Preparation of complementary and/or compound feed for onwards supply to other

holdings

5

Most common additives used on farm include urea, preservatives such as propionic acid, vitamins A and D, trace elements (such as copper, selenium, zinc etc). The FSA has agreed that, on the basis of proportionality it would be sufficient for farmers to apply the principles of HACCP and meet the requirements of Annex II of EC Regulation 183/1005, only to activities relating to the use of such preservatives, and not to all other on- farm activities when the conditions of Annex I of the Regulations would apply.



ANNEX 57


ANNEX 6: WILD GAME

Wild game is defined in Regulation (EC) 853/2004 as:

“Wild ungulates and lagomorphs, as well as other land mammals that are hunted for

human consumption and are considered to be wild under the applicable law in the Member

State concerned, including mammals living in enclosed territory under conditions of

freedom similar to those of wild game”.

Although some game animals may live in enclosures, they may still be classified as wild.

Wild game must be killed by hunting if it is to be supplied for human consumption.

Wild game animals may therefore be provided with food in order to ensure that the animals

do not stray beyond the boundary of the estate. In this case, the estate is considered a

food and feed business operator (primary producer).

The hunting of wild game is considered a primary production activity. Hunters supplying

primary products are subject to the same exemptions as other primary producers

concerned with the supply of small quantities direct to the final consumer to local retailers

who supply the final consumer.

For more information, please refer to the Wild Game Guidance:

http://www.food.gov.uk/foodindustry/meat/wildgameguidance


http://www.food.gov.uk/foodindustry/meat/wildgameguidance

ANNEX 58


ANNEX 7: OTHER SOURCES OF INFORMATION

Please note that any guidance and links to guidance that are referenced throughout this

document are correct at the time of publication. Users should be aware that the referenced

guidance may be subject to change.

1. Cross Compliance

http://www.scotland.gov.uk/Topics/Agriculture/grants/Schemes/ccompliance

2. “Guidance for Enforcement Bodies: Enforcement of Hygiene Regulations on Egg

Production Sites in the United Kingdom” is available on the Food Standards Agency

website:

http://www.food.gov.uk/foodindustry/guidancenotes/hygguid/eggenforcement

3. “Managing Farm Manures for Food Safety - Guidelines for Growers to Reduce the

Risks of Microbiological Contamination of Ready to Eat Crops” is available on the Food

Standards Agency website:

http://www.food.gov.uk/multimedia/pdfs/manguidfinaldraft.pdf

The guide provides information on how to reduce the risks of contamination before and

after crop establishment, during the growing season and after harvest, as well as general

management.

4. Fresh Produce - For further information on production of fresh produce, refer to the Risk

assessment web based tool (FSA/HDC) and HDC/FSA Factsheet 13/10 Monitoring

Microbial Safety of Fresh Produce and the Guide to Good Hygiene Practice – Fresh

Produce 2009 (Fresh Produce Consortium)

http://www.safeproduce.eu

http://www.freshproduce.org.uk/

http://www.scotland.gov.uk/Topics/Agriculture/grants/Schemes/ccompliance

http://www.food.gov.uk/foodindustry/guidancenotes/hygguid/eggenforcement

http://www.food.gov.uk/multimedia/pdfs/manguidfinaldraft.pdf

http://www.safeproduce.eu/

http://www.freshproduce.org.uk/

ANNEX 59


ANNEX 8: CONTACTS

Animal Health For details of area offices:-

http://www.defra.gov.uk/animalhealth/about/contact-us/officemap.html

Jacqui Angus, Food Standards Agency, Scotland

Food Standards Agency

Tel: 01224 285175

Email: [email protected]

Pesticides Safety Directorate (Health & Safety Executive)

http://www.pesticides.gov.uk/corporate.asp?id=74

Scottish Environment Protection Agency (SEPA)

For details of area offices:

http://www.sepa.org.uk/about_us/contacting_sepa.aspx

Scottish Government, Animal By-Products

The Scottish Government , Rural and Environment Directorate

Animal Health & Welfare

P-Spur, Saughton House, Broomhouse Drive,

Edinburgh, EH11 3XD , Tel: 0300 244 9833

Scottish Government Rural Payments and Inspections Directorate (SGRPID)

Veterinary Medicines Directorate

For details of area offices:-

http://www.scotland.gov.uk/Topics/farmingrural/Agriculture/AOcontacts/ contacts

Woodham Lane, New Haw, Addlestone, Surrey KT15 3LS Email: [email protected]

Telephone 01932 336911

http://www.defra.gov.uk/animalhealth/about/contact-us/officemap.html

mailto:[email protected]

http://www.pesticides.gov.uk/corporate.asp?id=74

http://www.sepa.org.uk/about_us/contacting_sepa.aspx

http://www.scotland.gov.uk/Topics/farmingrural/Agriculture/AOcontacts/contacts

http://www.scotland.gov.uk/Topics/farmingrural/Agriculture/AOcontacts/contacts

mailto:[email protected]